The European Commission has published the European Union’s 2027 Combined Nomenclature, adding customs classifications for selected steel structures, aluminium scrap and industrial components from 1 January 2027. The revision does not itself expand the legal scope of the Carbon Border Adjustment Mechanism (CBAM), but requires exporters and their customers to distinguish existing CBAM-covered products from goods exposed only to a proposed extension.
Published on 30 October under Commission Implementing Regulation (EU) 2026/2163, the revised nomenclature is binding for customs classification from 1 January 2027. The Combined Nomenclature is the EU’s eight-digit product classification system, used for customs declarations, applicable tariff measures and detailed international trade statistics.
One new code, 7308 90 53, identifies tubular steel monopile foundations and sections used in wind turbines. The classification sits within heading 7308, already relevant to the EU’s CBAM coverage of iron and steel articles, and separates monopiles from other steel structures in customs records and trade statistics.
The revision also divides aluminium waste and scrap under heading 7602. New codes include 7602 00 20 for production waste and scrap, 7602 00 30 for used beverage cans and 7602 00 40 for used wheels; other classifications distinguish scrap by physical or chemical characteristics, including aluminium and silicon content.
Those distinctions add statistical detail to an industrial-material stream important to EU low-carbon metals supply chains, but aluminium scrap does not automatically become subject to CBAM certificate obligations. A separate iron-and-steel code, 7204 41 11, identifies certain ferrous waste containing a combined weight of at least 5% neodymium or praseodymium, without determining its carbon-border treatment.
Code 8503 00 30 separately identifies wind-turbine nacelle assemblies. It supports supply-chain monitoring but does not automatically place nacelles within the currently adopted CBAM product list.
Customs changes and CBAM exposure
The classifications take effect as the EU negotiates a separate proposal to extend CBAM to selected downstream steel and aluminium products. Legislative proposal COM(2025)989, under procedure 2025/0419(COD), envisages coverage expanding from 2028 and additional anti-circumvention measures, but the proposal is not final law.
The European Parliament adopted amendments to the proposed expansion on 15 September 2026. Any eventual product coverage must be assessed against the adopted text, rather than the Commission’s original proposal alone; the new customs codes do not settle which additional goods may be covered.
Steel fabricators exporting foundations and heavy structural components from outside the EU need to review customs documentation, product descriptions and embedded-emissions records. Exporters and suppliers in Serbia, Montenegro, Bosnia and Herzegovina and Türkiye, as well as other European industrial-supplier countries, need to reconcile their product codes with European customers’ classifications and identify whether goods are already covered or only potentially affected by the proposed expansion.
Steel-structure manufacturers, aluminium recyclers, industrial subcontractors and renewable-energy component suppliers may face additional documentation requirements even if their underlying emissions calculations do not change. The revision’s immediate effect is not a new carbon charge, but more detailed customs distinctions that can affect precursor accounting and monitoring of imports from third countries.
Companies comparing import volumes, values or supplier-country shares across years must use the official correlation between the 2026 and 2027 classifications. When an existing CN8 category is split into new codes, apparent changes in individual product categories may reflect reclassification rather than a change in physical trade.
Banks financing industrial exporters should check whether customer contracts, customs documents and CBAM exposure models identify the same products consistently. Inconsistent classification could lead to unreliable trade comparisons or incorrect assessments of current and future CBAM obligations, while the additional obligations remain subject to the legislative process.
